Presenting a live 90-minute webinar with interactive Q&A. Today s faculty features:

Size: px
Start display at page:

Download "Presenting a live 90-minute webinar with interactive Q&A. Today s faculty features:"

Transcription

1 Presenting a live 90-minute webinar with interactive Q&A Grantor Trusts After Divorce: Tax Reform, Fiduciary Challenges, and Minimizing Tax for Trust Transfers to Former Spouse Gift Tax Exemption on Divorce Transfers, Grantor Trust Rules, Gift-Splitting and Income Tax Rules WEDNESDAY, FEBRUARY 14, pm Eastern 12pm Central 11am Mountain 10am Pacific Today s faculty features: Audrey Young, Senior Manager, Private Client Services, RSM US, Boston Kenneth A. Goldstein, Partner, Horwood Marcus & Berk, Chicago The audio portion of the conference may be accessed via the telephone or by using your computer's speakers. Please refer to the instructions ed to registrants for additional information. If you have any questions, please contact Customer Service at ext. 1. NOTE: If you are seeking CPE credit, you must listen via your computer phone listening is no longer permitted.

2 Tips for Optimal Quality FOR LIVE EVENT ONLY Sound Quality If you are listening via your computer speakers, please note that the quality of your sound will vary depending on the speed and quality of your internet connection. If the sound quality is not satisfactory, you may listen via the phone: dial and enter your PIN when prompted. Otherwise, please send us a chat or sound@straffordpub.com immediately so we can address the problem. If you dialed in and have any difficulties during the call, press *0 for assistance. NOTE: If you are seeking CPE credit, you must listen via your computer phone listening is no longer permitted. Viewing Quality To maximize your screen, press the F11 key on your keyboard. To exit full screen, press the F11 key again.

3 Continuing Education Credits FOR LIVE EVENT ONLY In order for us to process your continuing education credit, you must confirm your participation in this webinar by completing and submitting the Attendance Affirmation/Evaluation after the webinar. A link to the Attendance Affirmation/Evaluation will be in the thank you that you will receive immediately following the program. For CPE credits, attendees must participate until the end of the Q&A session and respond to five prompts during the program plus a single verification code. In addition, you must confirm your participation by completing and submitting an Attendance Affirmation/Evaluation after the webinar. For additional information about continuing education, call us at ext. 2.

4 Program Materials FOR LIVE EVENT ONLY If you have not printed the conference materials for this program, please complete the following steps: Click on the ^ symbol next to Conference Materials in the middle of the lefthand column on your screen. Click on the tab labeled Handouts that appears, and there you will see a PDF of the slides for today's program. Double click on the PDF and a separate page will open. Print the slides by clicking on the printer icon.

5 Grantor Trusts After Divorce: Tax Reform, Fiduciary Challenges & Minimizing Tax for Trust Transfers to Former Spouse 2/14/18 Strafford Publications

6 Presenters Audrey Young Senior Manger, Private Client Services RSM US P: E: Kenneth A. Goldstein Partner Horwood Marcus & Berk P: E: 6 6

7 Agenda New tax law touches on many aspects of divorce Effective dates are key (Hint: not all of the changes in TCJA were effective 12/31/17) Three buckets: old rules still in effect, new rules in effect, new rules that will be in effect 12/31/18 And then there is the sunset 7

8 Agenda (Cont.) Grantor trust planning The continuing importance of grantor trusts How to navigate potential for divorce How to structure in the event of divorce Income tax rules on termination of grantor status New rules under TCJA alimony and alimony trusts Old rules still in effect: IRC 2516 and 1041 Basis management for divorcing spouses 8

9

10 IDGTS An Intentionally Defective Grantor Trust ( IDGT ) is an irrevocable trust that is not included in the grantor s gross estate However, the trust income is taxable to the grantor even though the grantor is not a beneficiary of the trust If the IDGT is structured so it is GST exempt, trust property also passes estate tax free from one generation to the next for the maximum period permitted under state law Assets are protected from creditors Powerful estate planning technique since the grantor s payment of the income tax on the trust income reduces the grantor s taxable estate Grantor s payment of income tax on the trust s income is not considered a gift 10

11 IDGTs Grantor Gifts $11.18M IDGT $11.18M Children GrandChildren The trustee can distribute income and principal to the beneficiaries based on the standard set forth in the trust agreement (i.e.. best interests or support standard) 11

12 IDGTS Grantor Trust vs. Non-Grantor Trust NON-GRANTOR TRUST GRANTOR TRUST Year Beginning Balance Taxable 8% Income 40% Ending Balance Year Beginning Balance Taxable Income Ending Balance 1 $11,180,000 $894,400 $357,760 $11,716,640 1 $11,180,000 $894,400 $0 $12,074,400 2 $11,716,640 $937,331 $374,932 $12,279,039 2 $12,074,400 $965,952 $0 $13,040,352 3 $12,279,039 $982,323 $392,929 $12,868,433 3 $13,040,352 $1,043,228 $0 $14,083,580 4 $12,868,433 $1,029,475 $411,790 $13,486,117 4 $14,083,580 $1,126,686 $0 $15,210,267 5 $13,486,117 $1,078,889 $431,556 $14,133,451 5 $15,210,267 $1,216,821 $0 $16,427,088 6 $14,133,451 $1,130,676 $452,270 $14,811,857 6 $16,427,088 $1,314,167 $0 $17,741,255 7 $14,811,857 $1,184,949 $473,979 $15,522,826 7 $17,741,255 $1,419,300 $0 $19,160,555 8 $15,522,826 $1,241,826 $496,730 $16,267,921 8 $19,160,555 $1,532,844 $0 $20,693,400 9 $16,267,921 $1,301,434 $520,573 $17,048,782 9 $20,693,400 $1,655,472 $0 $22,348, $17,048,782 $1,363,903 $545,561 $17,867, $22,348,872 $1,787,910 $0 $24,136, $17,867,123 $1,429,370 $571,748 $18,724, $24,136,781 $1,930,943 $0 $26,067, $18,724,745 $1,497,980 $599,192 $19,623, $26,067,724 $2,085,418 $0 $28,153, $19,623,533 $1,569,883 $627,953 $20,565, $28,153,142 $2,252,251 $0 $30,405, $20,565,462 $1,645,237 $658,095 $21,552, $30,405,393 $2,432,431 $0 $32,837, $21,552,605 $1,724,208 $689,683 $22,587, $32,837,825 $2,627,026 $0 $35,464,851 12

13 Gifts to IDGTS Removes appreciation of gifted assets from grantor s estate Technique can be further leveraged by using assets that may be discounted for valuation purposes Preserves use of sunsetting gift-tax exemption (potential clawback if die after 2025) 13

14 Low Interest Loans to IDGTS The grantor loans cash or other assets to the trust in exchange for a promissory note The promissory note bears interest equal to the Applicable Federal Rate (AFR) Any income and appreciation of the trust assets in excess of the AFR remains in the trust for the benefit of the beneficiaries 14

15 Sales to IDGTS The grantor sells assets to the trust in exchange for a promissory note Technique can be further leveraged by using assets that may be discounted for valuation purposes The promissory note bears interest equal to the Applicable Federal Rate (AFR) Any income and appreciation of the trust assets in excess of the AFR remains in the trust for the benefit of the beneficiaries 15

16 Spousal Lifetime Access Trust A Spousal Lifetime Access Trust ( SLAT ) is an IDGT in which the grantor s spouse is a discretionary beneficiary of the trust The purpose of this trust is to provide a source of cash flow to the grantor s spouse (or at least alleviate some of the concern that the grantor s spouse (and indirectly, the grantor) will deplete their funds during their lifetimes) If properly structured, the trust will not be included in either the Grantor or the Grantor s spouse s taxable estate Especially desirable with sun-setting of gift tax exemption after 2025 Could have each spouse create a SLAT for the other but need to structure in a manner to avoid reciprocal trust doctrine 16

17

18 Spousal Lifetime Access Trusts Grantor Gifts $11.18M IDGT $11.18M Spouse Children GrandChildren The trustee can distribute income and principal to the beneficiaries based on the standard set forth in the trust agreement (i.e.. best interests or support standard). However, if spouse will be acting as sole trustee, distributions must be based on a support standard. Grantor maintains indirect access to the trust assets. 18

19 Spousal Lifetime Access Trust After Divorce Trust Contains Provision that Provides that Spouse is Deemed to be Deceased Upon Divorce (Kick Out Provision) Should be possible to turn off grantor trust status Trust Does Not Contain Any Provision that Provides that Spouse is Deemed to be Deceased Upon Divorce (No Kick Out Provision) Current IRC Code 672 (As Amended by the Technical Corrections Act of 1988) provides: (e) Grantor treated as holding any power or interest of grantor s spouse (1) In general. For purposes of this subpart, a grantor shall be treated as holding any power or interest held by» (A) any individual who was the spouse of the grantor at the time of the creation of such power or interest, or» (B) any individual who became the spouse of the grantor after the creation of such power or interest, but only with respect to periods after such individual became the spouse of the grantor (2) Marital status For purposes of paragraph (1)(A), an individual legally separated from his spouse under a decree of divorce or of separate maintenance shall not be considered as married Original IRC Code 672 (Tax Reform Act of 1986) provided: "(e) For purposes of this subpart, if a grantor's spouse is living with the grantor at the time of the creation of any power or interest held by such spouse, the grantor shall be treated as holding such power or interest" 19

20 Spousal Lifetime Access Trust After Divorce Majority position seems to be that spousal attribution continues after divorce If Grantor and spouse were married at the time of creation of any power or interest or were living together at the time of such creation, divorce does not cut off spouse attribution under Section 672(e) If spouse remains a beneficiary of the trust, this means that it is not possible to turn off grantor trust status after divorce until death of spouse or death of grantor unless distributions can only be made to the grantor s spouse with the consent of an adverse party Not aware of any case or ruling that has definitively addressed this issue 20

21 Spousal Lifetime Access Trust After Divorce Minority Position is that Spousal Attribution ceases upon divorce Was the intent of 672(e) to provide that spousal attribution continues after divorce? Reg (a)-1(b)(2) provides: With respect to the treatment of a grantor as the owner of a portion of a trust solely because its income is, or may be, distributed or held or accumulated for future distribution to a beneficiary who is his spouse or applied to the payment of premiums for insurance on the spouse's life, section 677(a) applies to the income of a trust solely during the period of the marriage of the grantor to a beneficiary Reg (k)(1) Ex. 10 also provides that spousal attribution is cut off on divorce: Example 10. (i) Transfers to QTIP trust. On June 1, 1996, A transferred S corporation stock to a trust for the benefit of A's spouse B, the terms of which satisfy the requirements of section 2523(f)(2) as qualified terminable interest property. Under the terms of the trust, B is the sole income beneficiary for life. In addition, corpus may be distributed to B, at the trustee's discretion, during B's lifetime. [portion omitted] (ii) Transfers to QTIP trust where husband and wife divorce. Assume the same facts as in paragraph (i) of this Example 10, except that A and B divorce on May 2, Under section 682, A ceases to be treated as the owner of the trust under section 677(a) because A and B are no longer husband and wife. Under section 682, after the divorce, B is the income beneficiary of the trust and corpus of the trust may only be distributed to B. Accordingly, assuming the trust otherwise meets the requirements of section 1361(d)(3), B must make the QSST election within 2 months and 15 days after the date of the divorce 21

22 Spousal Lifetime Access Trust After Divorce Planning Ideas if Majority Position is Correct: Have adverse party serve as trustee or require consent of an adverse party for any distributions to the grantor s spouse Provide for lump sum payment to grantor to reimburse grantor for anticipated grantor trust taxes Include reimbursement provisions in Marital Settlement Agreement to the extent trust does not reimburse grantor for income taxes of grantor trust Have spouse create trust for the benefit of grantor to be used to reimburse grantor for each year for income taxes of grantor trust Have spouse agree to exercise LPOA to appoint assets, in whole or in part, to new trust which does not include spouse as a beneficiary and trustee (or take other steps permitted by trust agreement to eliminate spouse as a beneficiary and trustee of the trust) Same as item 3 but trust allows a spouse friendly person to appoint trust property to spouse Have grantor friendly trustee to try to minimize income tax consequences (or split roles so person who makes distribution decisions is a person who is spouse friendly and person who makes investment decisions is a person who is grantor friendly 22

23 IRC Section 2516 Certain transfers between former spouses are deemed to be for full and adequate consideration Timing considerations Actual payments must be traceable to written agreement Has less significance given current lifetime exemption but consider snap back 23

24 Don t forget gift-splitting rules To be eligible for gift split, couple must be married at the time of the gift (and neither may remarry during the calendar year) How to handle required consent Liability is joint and several Applies to all gifts made in a calendar year and eligible for gift splitting. Application to spousal trusts 24

25 IRC Section 1041 Prevents recognition of income, gain or loss on transfers of property between spouses incident to divorce Rules on timing Don t lose sight of tax on the ultimate disposition of assets by the spouse that receives the asset pursuant to the divorce decree Can couples work together to lower overall future tax impact and plan for each other s tax attributes and effective rates 25

26 Dividing closely-held business or investment interests Ben and Jen are divorcing. Jen owns a 50% interest in Intellijen LLC, which is taxed as a partnership. Her tax basis is $200,000 and her interest has an FMV of $400,000. She plans to give Ben $120,000 under the divorce decree If Intellijen redeemed a portion of Jen s interest so that she had sufficient funds to pay Ben $120,000 under section 1041, she would not be taxed though she would lose most of her basis in Intellijen If she transferred an interest worth $120,000 to Ben and then he redeemed that interest, the redemption would not be protected under section 1041 so he would recognize capital gain income What if Ben did not redeem? What does the silent partner think of these events? What does the partnership agreement say? 26

27 Alimony Repeal of deduction for alimony payments for divorce or separation agreements entered into after December 31, 2018 Also applies to modifications to divorce or separation agreements entered into before December 31, 2018 if the modification expressly provides that the TCJA is to apply Does the TCJA provide an opportunity for both parties to agree to change taxation of pre 2019 orders? How will judges react to a unilateral request to change the taxation of pre 2019 orders? prenuptial agreements that address alimony should be reviewed TCJA change affects alimony negotiations Will states that have set alimony formulas revise their laws? Treatment of child support payments is unchanged 27

28 Section 682 is repealed Section 682 overrides grantor trust rules but is repealed by TCJA The repeal of the provision relating to alimony and Section 682 trusts apply to any divorce or separation instrument (as defined by Section 71(b)(2) prior to its repeal), executed after Dec. 31, 2018 Divorce and separation agreements executed on or before the law s Dec. 31, 2018 effective date will be grandfathered. Grandfathered agreements modified after the Dec. 31, 2018 effective date will also be grandfathered unless the modification expressly provides that the modified agreement be governed by the new law. 28

29 New rule no personal exemptions and SALT limitation Many separation agreements allocate the personal exemptions for children Example of rule that sunsets on 12/31/25 SALT deduction capped at $10,000 example of marriage penalty after divorce, each spouse would get $10,000 how will divorcing couples account for this 29

30 Section 121 unchanged but still complicated For many couples, residence is one of most significant joint assets Section 121 permits homeowners to avoid tax on gain of up to $250,000 (or $500,000 if married filing a joint return) Helpful ownership definitions for divorcing spouses How do modern day nesting arrangements work with Section 121 Consider taxes on future disposition of house 30

31 Questions? Audrey Young Senior Manger, Private Client Services RSM US P: E: Kenneth A. Goldstein Partner Horwood Marcus & Berk P: E: Note that these materials are intended for general informational purposes only and should be used only as a starting point for addressing the issues raised herein. This document does not constitute audit, tax, consulting, business, financial, investment, legal or other professional advice, and you should consult a qualified professional advisor before taking any action based on the information herein. Horwood, Marcus & Berk and RSM US LLP (and its affiliates and related entities) are not responsible for any loss resulting from or relating to reliance on this document by any person. Internal Revenue Service rules require us to inform you that this communication may be deemed a solicitation to provide tax services. This communication is being sent to individuals who have subscribed to receive it or who we believe would have an interest in the topics discussed. Also note that any U.S. federal tax advice contained in these materials are not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. RSM US LLP is a limited liability partnership and the U.S. member firm of RSM International, a global network of independent audit, tax and consulting firms. The member firms of RSM International collaborate to provide services to global clients, but are separate and distinct legal entities that cannot obligate each other. Each member firm is responsible only for its own acts and omissions, and not those of any other party. Visit rsmus.com/about us for more information regarding RSM US LLP and RSM International. 31

Estate Planning and Tax Reform: Wealth Transfer Structures Under the New Tax Law

Estate Planning and Tax Reform: Wealth Transfer Structures Under the New Tax Law Presenting a live 90-minute webinar with interactive Q&A Estate Planning and Tax Reform: Wealth Transfer Structures Under the New Tax Law WEDNESDAY, FEBRUARY 7, 2018 1pm Eastern 12pm Central 11am Mountain

More information

Presenting a live 90-minute webinar with interactive Q&A. Today s faculty features: Brian E. Hammell, Esq., Sullivan & Worcester, Boston

Presenting a live 90-minute webinar with interactive Q&A. Today s faculty features: Brian E. Hammell, Esq., Sullivan & Worcester, Boston Presenting a live 90-minute webinar with interactive Q&A Buy-Sell Agreements for Corporations and LLCs: Drafting Stock Redemption, Cross-Purchase and Mixed Agreements Navigating Complex Corporate, Tax,

More information

Estate Planning With Grantor Trusts: Leveraging GRATs and IDGTs to Minimize Taxes, Preserve and Transfer Assets

Estate Planning With Grantor Trusts: Leveraging GRATs and IDGTs to Minimize Taxes, Preserve and Transfer Assets Presenting a live 90-minute webinar with interactive Q&A Estate Planning With Grantor Trusts: Leveraging GRATs and IDGTs to Minimize Taxes, Preserve and Transfer Assets THURSDAY, OCTOBER 15, 2015 1pm Eastern

More information

Springing the Delaware Tax Trap: Drafting Limited Powers of Appointment to Increase Asset Income Tax Basis

Springing the Delaware Tax Trap: Drafting Limited Powers of Appointment to Increase Asset Income Tax Basis Presenting a live 90-minute webinar with interactive Q&A Springing the Delaware Tax Trap: Drafting Limited Powers of Appointment to Increase Asset Income Tax Basis TUESDAY, JUNE 28, 2016 1pm Eastern 12pm

More information

Survivor Benefit Plans and Military Divorce: Defending Against or Claiming Former-Spouse SBP Coverage

Survivor Benefit Plans and Military Divorce: Defending Against or Claiming Former-Spouse SBP Coverage Presenting a live 90-minute webinar with interactive Q&A Survivor Benefit Plans and Military Divorce: Defending Against or Claiming Former-Spouse SBP Coverage WEDNESDAY, JUNE 28, 2017 1pm Eastern 12pm

More information

Presenting a live 90-minute webinar with interactive Q&A. Today s faculty features:

Presenting a live 90-minute webinar with interactive Q&A. Today s faculty features: Presenting a live 90-minute webinar with interactive Q&A Structuring and Operating Family Limited Partnerships: Asset Protection and Income Tax Reduction Shifting Income Tax Burden to Lower-Taxed Family

More information

Presenting a live 90-minute webinar with interactive Q&A. Today s faculty features:

Presenting a live 90-minute webinar with interactive Q&A. Today s faculty features: Presenting a live 90-minute webinar with interactive Q&A NING and DING Trusts in Estate Planning: Designing ING Trusts to Avoid State Income Tax and Protect Assets Effective Drafting of Incomplete Gift

More information

QDRO Drafting Boot Camp: Preparing QDROs for 401(k)s and Similar Defined Contribution Plans

QDRO Drafting Boot Camp: Preparing QDROs for 401(k)s and Similar Defined Contribution Plans Presenting a live 90-minute webinar with interactive Q&A QDRO Drafting Boot Camp: Preparing QDROs for 401(k)s and Similar Defined Contribution Plans Strategies for Family Law Practitioners to Help Ensure

More information

Presenting a live 90-minute webinar with interactive Q&A. Today s faculty features: Dean C. Berry, Partner, Cadwalader Wickersham & Taft, New York

Presenting a live 90-minute webinar with interactive Q&A. Today s faculty features: Dean C. Berry, Partner, Cadwalader Wickersham & Taft, New York Presenting a live 90-minute webinar with interactive Q&A Estate Planning Involving Resident and Non-Resident Aliens Navigating Estate, Gift and GST Tax Rules; Leveraging Estate and Lifetime Gifting Opportunities

More information

Private Investment Funds and Tax Reform

Private Investment Funds and Tax Reform Presenting a live 90-minute webinar with interactive Q&A Private Investment Funds and Tax Reform Carried Interest, QBI and Interest Deductions, Sale of Partnership Interests, Computation of UBTI, and More

More information

Scott J. Bakal, Partner, Neal Gerber & Eisenberg, Chicago Robert C. Stevenson, Attorney, Skadden Arps Slate Meagher & Flom, Washington, D.C.

Scott J. Bakal, Partner, Neal Gerber & Eisenberg, Chicago Robert C. Stevenson, Attorney, Skadden Arps Slate Meagher & Flom, Washington, D.C. Presenting a live 90-minute webinar with interactive Q&A : Tax Basis Step-Up Through Deemed Asset Sale Treatment Structuring Qualifying Stock Dispositions for Partnership and Private Equity Acquirers WEDNESDAY,

More information

Structuring Equity Compensation for Partnerships and LLCs Navigating Capital and Profits Interests Plus Section 409A and Tax Consequences

Structuring Equity Compensation for Partnerships and LLCs Navigating Capital and Profits Interests Plus Section 409A and Tax Consequences Presenting a live 90-minute webinar with interactive Q&A Structuring Equity Compensation for Partnerships and LLCs Navigating Capital and Profits Interests Plus Section 409A and Tax Consequences TUESDAY,

More information

Drafting Income-Only Trusts for Medicaid Eligibility and Tax Planning

Drafting Income-Only Trusts for Medicaid Eligibility and Tax Planning Presenting a live 90-minute webinar with interactive Q&A Drafting Income-Only Trusts for Medicaid Eligibility and Tax Planning Navigating Look-Back, Grantor Trust, Basis and Gift Tax Rules WEDNESDAY, OCTOBER

More information

Protecting Business Assets From Creditors in Litigation: Strategic Choice of Entities, Avoiding Fraudulent Transfers

Protecting Business Assets From Creditors in Litigation: Strategic Choice of Entities, Avoiding Fraudulent Transfers Presenting a live 90-minute webinar with interactive Q&A Protecting Business Assets From Creditors in Litigation: Strategic Choice of Entities, Avoiding Fraudulent Transfers TUESDAY, JULY 21, 2015 1pm

More information

Advanced Trust Drafting for Income Tax Minimization: Including Capital Gains in DNI, Push-Outs and More

Advanced Trust Drafting for Income Tax Minimization: Including Capital Gains in DNI, Push-Outs and More Presenting a live 90-minute webinar with interactive Q&A Advanced Trust Drafting for Income Tax Minimization: Including Capital Gains in DNI, Push-Outs and More Managing the Disparity in Income Tax Treatment

More information

Commercial Lease Negotiations: Property and Liability Insurance, Proof of Coverage, AI and Loss Payee Issues

Commercial Lease Negotiations: Property and Liability Insurance, Proof of Coverage, AI and Loss Payee Issues Presenting a live 90-minute webinar with interactive Q&A Commercial Lease Negotiations: Property and Liability Insurance, Proof of Coverage, AI and Loss Payee Issues Structuring Lease Provisions to Require

More information

ERISA Compliance and Monitoring 401(k) Investments: Safe Harbor Rules and Appointing Advisers

ERISA Compliance and Monitoring 401(k) Investments: Safe Harbor Rules and Appointing Advisers Presenting a live 90-minute webinar with interactive Q&A ERISA Compliance and Monitoring 401(k) Investments: Safe Harbor Rules and Appointing Advisers TUESDAY, APRIL 3, 2018 1pm Eastern 12pm Central 11am

More information

Grantor Retained Annuity Trusts in 2013: Tax-Efficient Estate Planning Techniques Leveraging GRATs to Preserve and Transfer Assets

Grantor Retained Annuity Trusts in 2013: Tax-Efficient Estate Planning Techniques Leveraging GRATs to Preserve and Transfer Assets Presenting a live 90-minute webinar with interactive Q&A Grantor Retained Annuity Trusts in 2013: Tax-Efficient Estate Planning Techniques Leveraging GRATs to Preserve and Transfer Assets WEDNESDAY, MARCH

More information

Presenting a live 90-minute webinar with interactive Q&A. Today s faculty features:

Presenting a live 90-minute webinar with interactive Q&A. Today s faculty features: Presenting a live 90-minute webinar with interactive Q&A Converting to Nongrantor Trusts to Minimize Income Tax: Maximizing Increased Exemption Benefits Switching Off Grantor Trust Features in Existing

More information

Presenting a live 90-minute webinar with interactive Q&A. Today s faculty features:

Presenting a live 90-minute webinar with interactive Q&A. Today s faculty features: Presenting a live 90-minute webinar with interactive Q&A Transactional Risk Insurance in M&A: Reps and Warranties, Contingent Liability and More Leveraging Insurance to Allocate Risk and Protect Deal Value;

More information

ERISA Retirement Plan Investment Management Agreements: Guidance for Plan Sponsors to Minimize Risks

ERISA Retirement Plan Investment Management Agreements: Guidance for Plan Sponsors to Minimize Risks Presenting a live 90-minute webinar with interactive Q&A ERISA Retirement Plan Investment Management Agreements: Guidance for Plan Sponsors to Minimize Risks Selecting 3(38) Investment Managers, Negotiating

More information

U.S.-Israeli Estate Tax Planning for Dual Citizens

U.S.-Israeli Estate Tax Planning for Dual Citizens Presenting a 90-Minute Encore Presentation of the Webinar with Live, Interactive Q&A U.S.-Israeli Estate Tax Planning for Dual Citizens Reconciling U.S. and Israeli Law on Trust Taxation, Inheritance Laws,

More information

Completion Guaranties in Construction Lending: Key Provisions for Lenders and Guarantors

Completion Guaranties in Construction Lending: Key Provisions for Lenders and Guarantors Presenting a live 90-minute webinar with interactive Q&A Completion Guaranties in Construction Lending: Key Provisions for Lenders and Guarantors TUESDAY, MARCH 6, 2018 1pm Eastern 12pm Central 11am Mountain

More information

Impact of Tax Reform on ABLE Accounts and Special Needs Trusts: Guidance for Elder Law Attorneys

Impact of Tax Reform on ABLE Accounts and Special Needs Trusts: Guidance for Elder Law Attorneys Presenting a live 90-minute webinar with interactive Q&A Impact of Tax Reform on ABLE Accounts and Special Needs Trusts: Guidance for Elder Law Attorneys THURSDAY, SEPTEMBER 27, 2018 1pm Eastern 12pm Central

More information

Structuring Preferred Partnership Freezes in Estate Planning: Navigating IRC Chapter 14 Valuation Rules

Structuring Preferred Partnership Freezes in Estate Planning: Navigating IRC Chapter 14 Valuation Rules Presenting a live 90-minute webinar with interactive Q&A Structuring Preferred Partnership Freezes in Estate Planning: Navigating IRC Chapter 14 Valuation Rules WEDNESDAY, MARCH 30, 2016 1pm Eastern 12pm

More information

Presenting a live 90-minute webinar with interactive Q&A. Today s faculty features:

Presenting a live 90-minute webinar with interactive Q&A. Today s faculty features: Presenting a live 90-minute webinar with interactive Q&A Estate Tax Planning Opportunities in 2012 Maximizing Benefits Under Current Gift and Estate Tax Law: Portability, Lifetime Exemptions, Trust Use

More information

Creatively Completing The Capital Stack: Real Estate GP Private Equity Funds

Creatively Completing The Capital Stack: Real Estate GP Private Equity Funds Presenting a live 90-minute webinar with interactive Q&A Creatively Completing The Capital Stack: Real Estate GP Private Equity Funds Structuring Key Deal Terms Regarding Distribution, Sharing of Promote

More information

Universal Health Services v. Escobar: Avoiding Implied Certification Liability Under FCA

Universal Health Services v. Escobar: Avoiding Implied Certification Liability Under FCA Presenting a live 30-minute webinar with interactive Q&A Universal Health Services v. Escobar: Avoiding Implied Certification Liability Under FCA MONDAY, JULY 25, 2016 1pm Eastern 12pm Central 11am Mountain

More information

Asset Sale vs. Stock Sale: Tax Considerations, Advanced Drafting and Structuring Techniques for Tax Counsel

Asset Sale vs. Stock Sale: Tax Considerations, Advanced Drafting and Structuring Techniques for Tax Counsel Presenting a live 90-minute webinar with interactive Q&A Asset Sale vs. Stock Sale: Tax Considerations, Advanced Drafting and Structuring Techniques for Tax Counsel TUESDAY, AUGUST 2, 2016 1pm Eastern

More information

Foreign Investment in U.S. Real Estate: Impact of Tax Reform

Foreign Investment in U.S. Real Estate: Impact of Tax Reform Presenting a live 90-minute webinar with interactive Q&A Foreign Investment in U.S. Real Estate: Impact of Tax Reform Entity Selection, FIRPTA, Tax Concerns When Acquiring or Disposing of Ownership Interests

More information

Trust Dispositions of IRAs and Qualified Plans: Structuring See-Through Trusts and Stretch Provisions

Trust Dispositions of IRAs and Qualified Plans: Structuring See-Through Trusts and Stretch Provisions Presenting a live 90-minute webinar with interactive Q&A Trust Dispositions of IRAs and Qualified Plans: Structuring See-Through Trusts and Stretch Provisions TUESDAY, JANUARY 17, 2017 1pm Eastern 12pm

More information

Structuring Equity Compensation for Partnerships and LLCs Navigating Capital and Profits Interests Plus Section 409A and Tax Consequences

Structuring Equity Compensation for Partnerships and LLCs Navigating Capital and Profits Interests Plus Section 409A and Tax Consequences Presenting a live 110-minute webinar with interactive Q&A Structuring Equity Compensation for Partnerships and LLCs Navigating Capital and Profits Interests Plus Section 409A and Tax Consequences THURSDAY,

More information

New Section 199A: Structuring Real Estate Transactions to Take Advantage of the Qualified Business Income Deduction

New Section 199A: Structuring Real Estate Transactions to Take Advantage of the Qualified Business Income Deduction Presenting a 90-minute encore presentation featuring live Q&A New Section 199A: Structuring Real Estate Transactions to Take Advantage of the Qualified Business Income Deduction THURSDAY, JANUARY 17, 2019

More information

Clearing Title for Defects Due to Mortgage-Related Issues, Legal Description Errors, and Foreclosure

Clearing Title for Defects Due to Mortgage-Related Issues, Legal Description Errors, and Foreclosure Presenting a live 90-minute webinar with interactive Q&A Clearing Title for Defects Due to Mortgage-Related Issues, Legal Description Errors, and Foreclosure Identifying and Resolving Common Title Defects

More information

Asset Spend-Down for Medicaid Qualification Navigating the Complexities of Classifying Assets, Individuals vs. Married Couples, and Appeals Process

Asset Spend-Down for Medicaid Qualification Navigating the Complexities of Classifying Assets, Individuals vs. Married Couples, and Appeals Process Presenting a live 90-minute webinar with interactive Q&A Asset Spend-Down for Medicaid Qualification Navigating the Complexities of Classifying Assets, Individuals vs. Married Couples, and Appeals Process

More information

Presenting a live 90-minute webinar with interactive Q&A. Today s faculty features:

Presenting a live 90-minute webinar with interactive Q&A. Today s faculty features: Presenting a live 90-minute webinar with interactive Q&A Special Needs Trusts and Guardianships: Protecting Government Benefits for the Disabled Crafting and Administering First- and Third-Party Trusts

More information

Presenting a live 90-minute webinar with interactive Q&A. Today s faculty features: Elizabeth A. Gartland, Esq., Fenwick & West, San Francisco

Presenting a live 90-minute webinar with interactive Q&A. Today s faculty features: Elizabeth A. Gartland, Esq., Fenwick & West, San Francisco Presenting a live 90-minute webinar with interactive Q&A Structuring Management Carve-Out Plans for Privately Held Corporations: Mechanics, Tax Obstacles and Optimization Guidance for Employee Benefits

More information

Executive Compensation: Tax and Other Considerations for Restricted Stock Awards

Executive Compensation: Tax and Other Considerations for Restricted Stock Awards Presenting a live 90-minute webinar with interactive Q&A Executive Compensation: Tax and Other Considerations for Restricted Stock Awards Strategies for Navigating Substantial Risk of Forfeiture Analysis,

More information

Presenting a live 110-minute teleconference with interactive Q&A

Presenting a live 110-minute teleconference with interactive Q&A Presenting a live 110-minute teleconference with interactive Q&A Valuation Challenges With $10 Million-and-Under Businesses Avoiding Mistakes With Built-In Gains and Taxes, Misuse of Market Data and Other

More information

Presenting a live 90-minute webinar with interactive Q&A. Today s faculty features:

Presenting a live 90-minute webinar with interactive Q&A. Today s faculty features: Presenting a live 90-minute webinar with interactive Q&A Equity Joint Ventures: Structuring Capital Contribution, Waterfall and Other Payment Provisions Promoted Interest, Carried Interest, Cash Flow Splits

More information

ERISA Pre-Approved and Customized Benefit Plans: Overhauled IRS Procedures and Determination Letter Process

ERISA Pre-Approved and Customized Benefit Plans: Overhauled IRS Procedures and Determination Letter Process Presenting a live 90-minute webinar with interactive Q&A ERISA Pre-Approved and Customized Benefit Plans: Overhauled IRS Procedures and Determination Letter Process TUESDAY, NOVEMBER 14, 2017 1pm Eastern

More information

Exercising Setoff and Recoupment Rights in Bankruptcy

Exercising Setoff and Recoupment Rights in Bankruptcy Presenting a live 90-minute webinar with interactive Q&A Exercising Setoff and Recoupment Rights in Bankruptcy Mutuality of Obligation; Disputed Transactions; Relief From Automatic Stay TUESDAY, NOVEMBER

More information

Presenting a live 90-minute webinar with interactive Q&A. Today s faculty features:

Presenting a live 90-minute webinar with interactive Q&A. Today s faculty features: Presenting a live 90-minute webinar with interactive Q&A Tax Reform: Impact on REITs, Real Estate Businesses and Investors Pass-Through Business and Interest Deductions, Cost Recovery, Carried Interest,

More information

Presenting a live 90-minute webinar with interactive Q&A. Today s faculty features:

Presenting a live 90-minute webinar with interactive Q&A. Today s faculty features: Presenting a live 90-minute webinar with interactive Q&A Qualified Opportunity Zones: New Tax Incentives for Commercial Real Estate and Other Investments Deferred Capital Gains and Tax Abatement Under

More information

Financing Multi-Family Housing: Structuring the Low Income House Tax Credit and Tax-Exempt Bonds Documenting Transactions for Investors and Developers

Financing Multi-Family Housing: Structuring the Low Income House Tax Credit and Tax-Exempt Bonds Documenting Transactions for Investors and Developers Presenting a live 90-minute webinar with interactive Q&A Financing Multi-Family Housing: Structuring the Low Income House Tax Credit and Tax-Exempt Bonds Documenting Transactions for Investors and Developers

More information

Fraudulent Conveyance Exposure for Intercorporate Guaranties, Integrated Transactions and Designated-Use Loans

Fraudulent Conveyance Exposure for Intercorporate Guaranties, Integrated Transactions and Designated-Use Loans Presenting a live 90-minute webinar with interactive Q&A Fraudulent Conveyance Exposure for Intercorporate Guaranties, Integrated Transactions and Designated-Use Loans Navigating the Contours of Section

More information

Private Equity Waterfall and Carried Interest Provisions: Economic and Tax Implications for Investors and Sponsors

Private Equity Waterfall and Carried Interest Provisions: Economic and Tax Implications for Investors and Sponsors Presenting a live 90-minute Encore Presentation of the Webinar with Live, Interactive Q&A Private Equity Waterfall and Carried Interest Provisions: Economic and Tax Implications for Investors and Sponsors

More information

VA Benefits and Medicaid Eligibility

VA Benefits and Medicaid Eligibility Presenting a live 90-minute webinar with interactive Q&A VA Benefits and Medicaid Eligibility Meeting Complex Requirements for Benefits Qualification and Application THURSDAY, FEBRUARY 16, 2012 1pm Eastern

More information

Presenting a live 90-minute webinar with interactive Q&A. Today s faculty features: James O. Lang, Shareholder, Greenberg Traurig, Tampa, Fla.

Presenting a live 90-minute webinar with interactive Q&A. Today s faculty features: James O. Lang, Shareholder, Greenberg Traurig, Tampa, Fla. Presenting a live 90-minute webinar with interactive Q&A Leveraging New Markets Tax Credits to Finance Community Development: Latest Regs, Guidance and Legal Developments Twinning With Historic Tax Credits,

More information

Presenting a 90-minute encore presentation featuring live Q&A. Today s faculty features:

Presenting a 90-minute encore presentation featuring live Q&A. Today s faculty features: Presenting a 90-minute encore presentation featuring live Q&A New Section 199A: Deductions, Limitations, Complexities and Opportunities for Pass-Through Entities Determining Qualified Business Income,

More information

Presenting a live 90-minute webinar with interactive Q&A. Today s faculty features:

Presenting a live 90-minute webinar with interactive Q&A. Today s faculty features: Presenting a live 90-minute webinar with interactive Q&A Choice of Entity Under the New Tax Law: Avoiding Tax Pitfalls in Operations, Ownership Changes, Exit Strategies Capital vs. Profits Interest, Allowable

More information

Drafting Irrevocable Silent Trusts: Preserving Privacy of Trust Assets from Spendthrift Beneficiaries

Drafting Irrevocable Silent Trusts: Preserving Privacy of Trust Assets from Spendthrift Beneficiaries Presenting a live 90-minute webinar with interactive Q&A Drafting Irrevocable Silent Trusts: Preserving Privacy of Trust Assets from Spendthrift Beneficiaries Balancing Fiduciary Duties, Selecting Trust

More information

Tax Allocation in Pass-Through Entities

Tax Allocation in Pass-Through Entities Presenting a live 110-minute teleconference with interactive Q&A Tax Allocation in Pass-Through Entities Minimizing Tax Impact Through Strategic Allocation of Income, Gains, Losses and Liabilities THURSDAY,

More information

Tax Strategies for Real Estate LLC and LP Agreements: Capital Commitments, Tax Allocations, Distributions, and More

Tax Strategies for Real Estate LLC and LP Agreements: Capital Commitments, Tax Allocations, Distributions, and More Presenting a live 90-minute webinar with interactive Q&A Tax Strategies for Real Estate LLC and LP Agreements: Capital Commitments, Tax Allocations, Distributions, and More Structuring Provisions to Achieve

More information

401(k) Plan Nondiscrimination Testing: Guidance for Employee Benefits Counsel

401(k) Plan Nondiscrimination Testing: Guidance for Employee Benefits Counsel Presenting a live 90-minute webinar with interactive Q&A 401(k) Plan Nondiscrimination Testing: Guidance for Employee Benefits Counsel Meeting IRS Requirements, Avoiding Corrective Distributions, Evaluating

More information

Property Management and Leasing Agreements: Key Provisions for Multi-Family, Office, Retail and Industrial Properties

Property Management and Leasing Agreements: Key Provisions for Multi-Family, Office, Retail and Industrial Properties Presenting a live 90-minute webinar with interactive Q&A Property Management and Leasing Agreements: Key Provisions for Multi-Family, Office, Retail and Industrial Properties Navigating Fees and Expenses,

More information

UCC Article 9 Blanket Asset Lien Exclusions and Purchase Money Security Interests

UCC Article 9 Blanket Asset Lien Exclusions and Purchase Money Security Interests Presenting a live 90-minute webinar with interactive Q&A UCC Article 9 Blanket Asset Lien Exclusions and Purchase Money Security Interests Navigating Statutory, Contractual and Other Exclusions to All

More information

Interest Rate Hedges in Real Estate Finance: Placing Swaps, Caps, and Collars on Floating Rate Loans

Interest Rate Hedges in Real Estate Finance: Placing Swaps, Caps, and Collars on Floating Rate Loans Presenting a live 90-minute webinar with interactive Q&A Interest Rate Hedges in Real Estate Finance: Placing Swaps, Caps, and Collars on Floating Rate Loans Understanding Pricing and Trade Confirmations,

More information

Structuring Leveraged Loans After Tax Reform: Concerns for Multinational Entities

Structuring Leveraged Loans After Tax Reform: Concerns for Multinational Entities Presenting a live 90-minute webinar with interactive Q&A : Concerns for Multinational Entities Section 956 Deemed Dividend Rules, Limits on Interest Deductions, Tax Distributions, Corporate vs. Pass-Through

More information

Minority Investors in LLCs: Contractual Limitations, Waivers of Fiduciary Duties, Other Key Provisions

Minority Investors in LLCs: Contractual Limitations, Waivers of Fiduciary Duties, Other Key Provisions Presenting a live 90-minute webinar with interactive Q&A Minority Investors in LLCs: Contractual Limitations, Waivers of Fiduciary Duties, Other Key Provisions Protecting Minority Interests, Choice of

More information

Allocating Operating Expenses in Commercial Real Estate Leases: Negotiating Strategies for Landlords and Tenants

Allocating Operating Expenses in Commercial Real Estate Leases: Negotiating Strategies for Landlords and Tenants Presenting a live 90-minute webinar with interactive Q&A Allocating Operating Expenses in Commercial Real Estate Leases: Negotiating Strategies for Landlords and Tenants Structuring Pass-Throughs, Exclusions,

More information

Presenting a live 90-minute webinar with interactive Q&A. Today s faculty features:

Presenting a live 90-minute webinar with interactive Q&A. Today s faculty features: Presenting a live 90-minute webinar with interactive Q&A Structuring Sprinkle Trusts to Minimize Income Tax Consequences to Trust and Beneficiaries Discretionary Distribution Strategies to Reduce Income

More information

Fiduciary Compliance in ESOP Transactions: Recent DOL Settlement Agreements

Fiduciary Compliance in ESOP Transactions: Recent DOL Settlement Agreements Presenting a live 90-minute webinar with interactive Q&A Fiduciary Compliance in ESOP Transactions: Recent DOL Settlement Agreements Implications of GBTC, FBTS and Alpha Settlement Agreements, Guidance

More information

Presenting a live 90-minute webinar with interactive Q&A. Today s faculty features:

Presenting a live 90-minute webinar with interactive Q&A. Today s faculty features: Presenting a live 90-minute webinar with interactive Q&A D&O Indemnification Provisions in Governance Documents and Agreements Drafting Effective Indemnity and Advancement Agreements to Protect Directors

More information

Corporate Governance of Subsidiaries: Board Roles and Responsibilities, Interplay With Parent Board, Liability Risks

Corporate Governance of Subsidiaries: Board Roles and Responsibilities, Interplay With Parent Board, Liability Risks Presenting a live 90-minute webinar with interactive Q&A Corporate Governance of Subsidiaries: Board Roles and Responsibilities, Interplay With Parent Board, Liability Risks THURSDAY, AUGUST 16, 2018 1pm

More information

Bankruptcy Section 506(c) Surcharge on Secured Collateral

Bankruptcy Section 506(c) Surcharge on Secured Collateral Presenting a live 90-minute webinar with interactive Q&A Bankruptcy Section 506(c) Surcharge on Secured Collateral Seeking or Defeating Recovery of Expenses for Preserving or Disposing of Collateral TUESDAY,

More information

UCC Article 9 Blanket Asset Lien Exclusions and Purchase Money Security Interests

UCC Article 9 Blanket Asset Lien Exclusions and Purchase Money Security Interests Presenting a live 90-minute webinar with interactive Q&A UCC Article 9 Blanket Asset Lien Exclusions and Purchase Money Security Interests Navigating Statutory, Contractual and Other Exclusions to All

More information

Allocating Risk in Real Estate Leases: Contractual Indemnities, Additional Insured Endorsements and Waivers of Subrogation

Allocating Risk in Real Estate Leases: Contractual Indemnities, Additional Insured Endorsements and Waivers of Subrogation Presenting a live 90-minute webinar with interactive Q&A Allocating Risk in Real Estate Leases: Contractual Indemnities, Additional Insured Endorsements and Waivers of Subrogation Structuring Lease Provisions

More information

Investment Adviser Advertising Rule: New SEC Guidance and Best Practices for Compliance

Investment Adviser Advertising Rule: New SEC Guidance and Best Practices for Compliance Presenting a live 90-minute webinar with interactive Q&A Investment Adviser Advertising Rule: New SEC Guidance and Best Practices for Compliance TUESDAY, NOVEMBER 21, 2017 1pm Eastern 12pm Central 11am

More information

Best Efforts and Commercially Reasonable Efforts in M&A Agreements: Drafting and Interpretation Challenges

Best Efforts and Commercially Reasonable Efforts in M&A Agreements: Drafting and Interpretation Challenges Presenting a live 90-minute webinar with interactive Q&A Best Efforts and Commercially Reasonable Efforts in M&A Agreements: Drafting and Interpretation Challenges Lessons From Case Law for Interpreting

More information

Opinion Letters in Commercial Real Estate Best Practices to Minimize Risk When Crafting Third Party Opinions on Loans and Acquisitions

Opinion Letters in Commercial Real Estate Best Practices to Minimize Risk When Crafting Third Party Opinions on Loans and Acquisitions Presenting a live 90 minute webinar with interactive Q&A Opinion Letters in Commercial Real Estate Best Practices to Minimize Risk When Crafting Third Party Opinions on Loans and Acquisitions TUESDAY,

More information

Reporting GRATS, GRUTS, ILITS and IDGTs on Form 709: GST Exemption Allocation Calculations and Strategies

Reporting GRATS, GRUTS, ILITS and IDGTs on Form 709: GST Exemption Allocation Calculations and Strategies FOR LIVE PROGRAM ONLY Reporting GRATS, GRUTS, ILITS and IDGTs on Form 709: GST Exemption Allocation Calculations and Strategies WEDNESDAY, JULY 13, 2016, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR

More information

High Volatility Commercial Real Estate Loans: Guidance for Developers and Lenders on HVCRE Rules and Loan Covenants

High Volatility Commercial Real Estate Loans: Guidance for Developers and Lenders on HVCRE Rules and Loan Covenants Presenting a 90 minute encore presentation High Volatility Commercial Real Estate Loans: Guidance for Developers and Lenders on HVCRE Rules and Loan Covenants Navigating Borrower Contributed Capital Rules,

More information

Leveraging Earnings-Stripping Regs for Foreign Investments: Maximizing Tax Savings, Minimizing IRS Scrutiny

Leveraging Earnings-Stripping Regs for Foreign Investments: Maximizing Tax Savings, Minimizing IRS Scrutiny Presenting a live 110-minute teleconference with interactive Q&A Leveraging Earnings-Stripping Regs for Foreign Investments: Maximizing Tax Savings, Minimizing IRS Scrutiny THURSDAY, FEBRUARY 6, 2014 1pm

More information

Tax Challenges for NPO Counsel: Excess Benefit Transactions for Executive Comp and Other Financial Dealings

Tax Challenges for NPO Counsel: Excess Benefit Transactions for Executive Comp and Other Financial Dealings Presenting a live 110-minute teleconference with interactive Q&A Tax Challenges for NPO Counsel: Excess Benefit Transactions for Executive Comp and Other Financial Dealings Identifying Prohibited Transactions

More information

Presenting a 90 minute encore presentation featuring live Q&A. Today s faculty features:

Presenting a 90 minute encore presentation featuring live Q&A. Today s faculty features: Presenting a 90 minute encore presentation featuring live Q&A New Section 951A: GILTI Rules for Individual and Non C Corporation CFC Shareholders Treatment of CFC income, Reporting Requirements, Planning

More information

Tax Reform for Pass-Through Entities: Impact of New Tax Law on Partnerships, LLCs and S-Corporations

Tax Reform for Pass-Through Entities: Impact of New Tax Law on Partnerships, LLCs and S-Corporations Presenting a live 90-minute webinar with interactive Q&A Tax Reform for Pass-Through Entities: Impact of New Tax Law on Partnerships, LLCs and S-Corporations Planning Techniques, Loopholes, Qualified Business

More information

Presenting a 90-minute encore presentation featuring live Q&A. Today s faculty features:

Presenting a 90-minute encore presentation featuring live Q&A. Today s faculty features: Presenting a 90-minute encore presentation featuring live Q&A Private Equity Waterfall and Carried Interest Provisions: Economic and Tax Implications for Investors and Sponsors Distributions, Clawbacks

More information

Social Security Claiming Strategies for Estate Planners: Updated for the 2015 Bipartisan Budget Bill

Social Security Claiming Strategies for Estate Planners: Updated for the 2015 Bipartisan Budget Bill Presenting a live 90-minute webinar with interactive Q&A Social Security Claiming Strategies for Estate Planners: Updated for the 2015 Bipartisan Budget Bill THURSDAY, DECEMBER 17, 2015 1pm Eastern 12pm

More information

Drafting Shareholder Agreements for Private Equity M&A Deals

Drafting Shareholder Agreements for Private Equity M&A Deals Presenting a live 90-minute webinar with interactive Q&A Drafting Shareholder Agreements for Private Equity M&A Deals Structuring Provisions on Board Composition and Duties, Drag-Along, Tag-Along, Information

More information

M&A Indemnification Deal Terms: 2017 Survey Results

M&A Indemnification Deal Terms: 2017 Survey Results Presenting a 60-minute encore presentation featuring live Q&A M&A Indemnification Deal Terms: 2017 Survey Results What's Market for Negotiating and Drafting Private Target Company Indemnification Terms

More information

Auto Injury Claim Recovery: Maximizing Pain and Suffering, Loss of Future Earning Capacity Damages

Auto Injury Claim Recovery: Maximizing Pain and Suffering, Loss of Future Earning Capacity Damages Presenting a live 90-minute webinar with interactive Q&A Auto Injury Claim Recovery: Maximizing Pain and Suffering, Loss of Future Earning Capacity Damages Leveraging Calculation Methodologies, Medical

More information

Structuring Preferred Equity Investments in Real Estate Ventures: Impact of True Equity vs. "Debt-Like" Equity

Structuring Preferred Equity Investments in Real Estate Ventures: Impact of True Equity vs. Debt-Like Equity Presenting a live 90-minute webinar with interactive Q&A Structuring Preferred Equity Investments in Real Estate Ventures: Impact of True Equity vs. "Debt-Like" Equity Negotiating Deal Terms, Investor

More information

UCC Article 9 Update: Searching and Filing Under New Amendments

UCC Article 9 Update: Searching and Filing Under New Amendments Presenting a live 90-minute webinar with interactive Q&A UCC Article 9 Update: Searching and Filing Under New Amendments Lessons Learned Under the Recent Rules, Best Practices for Secured Lenders WEDNESDAY,

More information

Presenting a live 90-minute webinar with interactive Q&A. Today s faculty features:

Presenting a live 90-minute webinar with interactive Q&A. Today s faculty features: Presenting a live 90-minute webinar with interactive Q&A Trust Situs for Dynasty Trusts and DAPTs: Key Differences Among Top-Tier States Selecting the Best Situs Among Nevada, Delaware, Alaska, South Dakota,

More information

Structuring Commercial Loan Documents to Protect Non-Affiliated Lenders

Structuring Commercial Loan Documents to Protect Non-Affiliated Lenders Presenting a live 90-minute webinar with interactive Q&A Structuring Commercial Loan Documents to Protect Non-Affiliated Lenders Negotiating and Drafting Provisions Involving Loan Buybacks, Additional

More information

Attendees seeking CPE credit must listen to the audio over the telephone.

Attendees seeking CPE credit must listen to the audio over the telephone. Presenting a live 110 minute teleconference with interactive Q&A New 3.8% Net Investment Income Tax: Planning for Closely Held Companies Navigating New Medicare Tax, Self Employment l Tax, and Capital

More information

Robert S. Barnett, Partner, Capell Barnett Matalon & Schoenfeld, Jericho, N.Y.

Robert S. Barnett, Partner, Capell Barnett Matalon & Schoenfeld, Jericho, N.Y. Presenting a live 90-minute webinar with interactive Q&A Advanced Trust Drafting for Income Tax Minimization: Including Capital Gains in DNI, Push-Outs and More Managing the Disparity in Income Tax Treatment

More information

Presenting a live 90-minute webinar with interactive Q&A. Today s faculty features:

Presenting a live 90-minute webinar with interactive Q&A. Today s faculty features: Presenting a live 90-minute webinar with interactive Q&A Builder's Risk and CGL Insurance for Construction Projects: Mitigating Developer and Contractor Risks Evaluating Scope of Coverage, Covered Losses,

More information

Insurance Coverage for Statutory and Liquidated Damages and Attorney Fees: Policyholder and Insurer Perspectives

Insurance Coverage for Statutory and Liquidated Damages and Attorney Fees: Policyholder and Insurer Perspectives Presenting a live 90-minute webinar with interactive Q&A Insurance Coverage for Statutory and Liquidated Damages and Attorney Fees: Policyholder and Insurer Perspectives Advocating Coverage for Statutory

More information

Final IRS Sect. 67(e) Regs for Estate and Trust Taxpayers: Applying the Required 2% Deduction Floor

Final IRS Sect. 67(e) Regs for Estate and Trust Taxpayers: Applying the Required 2% Deduction Floor Final IRS Sect. 67(e) Regs for Estate and Trust Taxpayers: Applying the Required 2% Deduction Floor WEDNESDAY, OCTOBER 15, 2014, 1:00-2:50 pm Eastern IMPORTANT INFORMATION This program is approved for

More information

Section 704, Targeted Allocations, and the Distribution Waterfall: Overcoming Challenges Absent IRS Guidance

Section 704, Targeted Allocations, and the Distribution Waterfall: Overcoming Challenges Absent IRS Guidance Section 704, Targeted Allocations, and the Distribution Waterfall: Overcoming Challenges Absent IRS Guidance Understanding the Economic Effect Test and How to Allocate Income or Loss Using Targeted Allocations

More information

IRC Section 338(h)(10) Election

IRC Section 338(h)(10) Election Presenting a live 110 minute teleconference with interactive Q&A IRC Section 338(h)(10) Election Strategies for Tax Counsel Leveraging the Election in Structuring Acquisitions, Dispositions and Asset and

More information

Trucking and Auto Injury Cases: Deposing Accident Reconstruction and Biomechanical Experts

Trucking and Auto Injury Cases: Deposing Accident Reconstruction and Biomechanical Experts Presenting a live 90-minute webinar with interactive Q&A Trucking and Auto Injury Cases: Deposing Accident Reconstruction and Biomechanical Experts WEDNESDAY, JULY 11, 2018 1pm Eastern 12pm Central 11am

More information

ERISA Considerations in Structuring Credit Facilities with Private Investment Funds

ERISA Considerations in Structuring Credit Facilities with Private Investment Funds Presenting a live 90-minute webinar with interactive Q&A ERISA Considerations in Structuring Credit Facilities with Private Investment Funds WEDNESDAY, AUGUST 15, 2018 1pm Eastern 12pm Central 11am Mountain

More information

30(b)(6) Depositions in Insurance Coverage and Bad Faith Litigation Preparing and Responding to Notices of Corporate Representative Depositions

30(b)(6) Depositions in Insurance Coverage and Bad Faith Litigation Preparing and Responding to Notices of Corporate Representative Depositions Presenting a live 90-minute webinar with interactive Q&A 30(b)(6) Depositions in Insurance Coverage and Bad Faith Litigation Preparing and Responding to Notices of Corporate Representative Depositions

More information

Presenting a live 90-minute webinar with interactive Q&A. Today s faculty features:

Presenting a live 90-minute webinar with interactive Q&A. Today s faculty features: Presenting a live 90-minute webinar with interactive Q&A Keys To Equity Financing: The Compliance Requirements for Lenders and Borrowers Structuring Loans Secured by Stock, Hedge Fund Shares, 40 Act Companies

More information

Presenting a live 90-minute webinar with interactive Q&A. Today s faculty features:

Presenting a live 90-minute webinar with interactive Q&A. Today s faculty features: Presenting a live 90-minute webinar with interactive Q&A Commercial Mortgage Modifications: Lien Priority, Title Insurance and Bankruptcy Issues Structuring Modification Agreements While Avoiding Legal

More information

Sandra Hernandez, Managing Director, WTAS, Los Angeles Jeanne Sullivan, Director, National Pass-Throughs Group, KPMG, Washington, D.C.

Sandra Hernandez, Managing Director, WTAS, Los Angeles Jeanne Sullivan, Director, National Pass-Throughs Group, KPMG, Washington, D.C. Presenting a live 110 minute teleconference with interactive Q&A Passive Activity Loss Rules: Strategies for Pass Throughs to Maximize Deductions Leveraging Latest Federal Guidance and Rulings to Establish

More information

Structuring Waterfall Provisions in LLC and Partnership Agreements Navigating Complex Distribution Structures, Minimizing Negative Tax Consequences

Structuring Waterfall Provisions in LLC and Partnership Agreements Navigating Complex Distribution Structures, Minimizing Negative Tax Consequences Presenting a 90-minute encore presentation featuring live Q&A Structuring Waterfall Provisions in LLC and Partnership Agreements Navigating Complex Distribution Structures, Minimizing Negative Tax Consequences

More information